The 45-Day Report Card: Have Trustees Explained Full Portability Yet? Not Yet

Forty-five days to launch. On 21 December 2026, Phase One of MPF full portability opens, and about one million employees who started their current job on or after 1 May 2025 will be able, once a calendar year, to move the whole of their employer mandatory-contribution balance to a scheme of their own choice. The legislation is gazetted and the date is locked. The education is not.

This article runs a pre-launch spot check: the Mandatory Provident Fund Schemes Authority (MPFA) central pages, the eMPF guides, and the trustees’ public transfer guides — the pages a member is most likely to land on before logging in, not the member-only areas behind a login. The verdict is blunt: the regulator has explained the rules, the trustees have not yet explained the new rules, and the one page that would let a member compare trustees does not exist.

The core proposition: the page lawmakers asked for, versus the page members see

In the Legislative Council reaction covered on 28 October, lawmaker Chau Siu-chung called for trustee information that is simplified and easy to compare. That is the right marking scheme. Before moving money, a member needs five answers on one page:

1. Am I eligible? (Did my current employment start on or after 1 May 2025?)
2. Which pot moves? (Employer and employee mandatory contributions, together or separately, in full.)
3. Which pot does not move? (Voluntary contributions, governed by the original scheme’s rules; guaranteed funds, subject to their guarantee conditions.)
4. How do I move it? (Through eMPF, with no employer approval needed.)
5. Where should I move it to? (A trustee comparison on fees, fund choice and performance, on the same page.)

Measured against those five, here is the scorecard.

The audit: what the spot check found

The MPFA central pages: rules explained, comparison missing

The MPFA’s introduction to full portability and its employee FAQs answer the core of the first four questions: Phase One starts 21 December 2026; it covers employees who entered the workforce or changed jobs on or after 1 May 2025; the transfer is the whole employer mandatory-contribution balance, once per calendar year, to a personal account in a scheme of the member’s choice; employer and employee portions can move together or separately, to the same or different schemes; employers keep contributing through their own scheme, unchanged. Semi-portability to date totals more than 1.1 million transfers worth about HK$59 billion, averaging about HK$4.5 billion a year in 2021–2025 — the old regime’s flow, which the new regime will now supersede for eligible members.

But the fifth question defeats the central pages too. The MPFA Fund Platform, with data as of 30 September 2026, covers 382 constituent funds with a median risk indicator of 9.86%, and lets members compare funds side by side, up to 10 at a time. That is comparing funds, not comparing trustees. To compare trustees, a member must still open each scheme brochure and line up fees fund by fund.

Trustees’ public transfer guides: two still state the old rule, one states only the old regime

The most striking finding is stale wording still sitting on public pages:

• Hang Seng’s “How to transfer your MPF” page still tables employer mandatory contributions as “Not transferable.” The same table correctly states that employee mandatory contributions transfer once a calendar year and that voluntary contributions are subject to the original scheme’s governing rules. Two rows remain correct today; the first row stops being correct for eligible employees on 21 December. No Phase One qualification appears alongside it.
• AIA’s Prime Value Choice scheme document carries the identical transfer table: employer mandatory contributions “Not transferable.” Correct under the old regime, un-updated for the new one.
• Manulife’s eMPF FAQ has the clearest steps, but for the old regime. Personal-account consolidation and Employee Choice Arrangement steps through eMPF are set out click by click, with no corresponding steps surfaced for the new employer-contribution transfer.
• Principal’s job-change page covers only the general case — moving to a new employer’s contribution account or keeping a personal account — with no mention of Phase One.

Fairness requires one qualification: these pages were all correct under the old regime, and trustees may already hold updates in member-only areas or in documents not indexed by search. The scope of this check is public transfer guides, and its conclusion is confined to that scope: the pages an unlogged-in member is most likely to find today do not answer the new regime’s first question. With 45 days to go, that gap should not be left for members to guess across.

The cost of no comparison page: incentives decide by default

The consequence of a missing comparison page was priced in the 23 October incentive-tracker article. The market-average fund expense ratio (FER) is about 1.36%; the Default Investment Strategy (DIS) actual average is about 0.77%, a gap of 0.59 percentage points. On a HK$250,000 balance that is about HK$1,475 a year; on the illustrative model used throughout this series — HK$5,000 a month, 7% gross return, monthly compounding — the 30-year gap is about HK$559,000.

Trustee-level gaps are just as real: the mpf.hk fee-history database (22 October 2026) puts the cheapest current trustee average at Bank of East Asia, 1.0738%, and the dearest at Manulife, 1.4188%, a gap of 0.345 percentage points, or about HK$863 a year on HK$250,000. Without a trustee comparison page, the most visible numbers a member meets are transfer incentives instead: Manulife’s HK$6,300 for a HK$1–2 million transfer-in, Bank of East Asia’s HK$88,888 for HK$5 million or more. An incentive is one-off; a fee gap is every year. When the comparison page is absent, the incentive page decides by default.

The compounding cost: 45 days late on education is not just information

The education gap is not abstract. GUM’s MPF confidence survey (13–15 August 2026, 808 respondents, published 21 October 2026) found only 18.2% fully understood full portability, 37.5% did not understand it well, and 44.5% had never heard of it. With public guides still stating the old rule 45 days before launch, the 81.8% who do not fully understand it face two bad outcomes: stay put and keep paying the 0.59-point gap every year, or move on an incentive and discover the forfeiture clause before the bonus lands, while the fee gap keeps running.

Timing makes it worse. The 2026 transfer window runs only from 21 to 31 December, with the 2027 quota resetting on 1 January. A member who first understands the rules in December does not have 45 days to decide; he has a handful of working days wedged into the Christmas holidays. Education delivered late compresses the execution window it was meant to open.

The fix: a three-box checklist before launch

Until trustees publish that page, members can run three checks themselves:

1. Eligibility box. Did my current employment start on or after 1 May 2025? Yes means Phase One; no means waiting for Phase Two legislation, which the Government aims to table in the Legislative Council by mid-2027. The start date decides; the scheme name does not.
2. Split-the-pots box. Divide the balance into four: employer mandatory contributions (transferable under Phase One), employee mandatory contributions (transferable all along, once a year), employer and employee voluntary contributions (governed by the original scheme’s rules, and not guaranteed to follow), and guaranteed funds (check the guarantee conditions first — transferring out can void the guarantee). Do not press any one-click transfer until all four boxes are sorted.
3. Comparison box. Refuse to decide on an incentive alone. Compare funds on the MPFA Fund Platform first, then trustee-average fees from the mpf.hk fee-history database — the 0.345-point Bank of East Asia versus Manulife gap is exactly the number a comparison page should print prominently. Divide the incentive by the annual fee saving to get a payback period; a transfer whose payback runs past the incentive’s holding period should wait.

For trustees, the remedy is cheap: one Phase One applicability note, one updated transfer table, and one trustee comparison page — average fee, number of funds, DIS fee, transfer incentive and forfeiture clause, five columns. The legislation gave 45 days of preparation. Education should not arrive after the law it is meant to explain.

After launch, this series will re-check the same public pages: whether they were updated before 21 December, and whether the first movers actually moved the employer half under the new rule. The scorecard will be marked again.

Scope and limits: spot check of public pages on 28 October 2026, covering the MPFA full-portability introduction and employee FAQs, the eMPF FAQs, the Hang Seng and AIA public transfer tables, the Manulife eMPF FAQ and the Principal job-change page; member-only areas and unindexed documents were not covered, and trustees with updates are invited to correct the record. Illustrative calculations assume 7% gross return with monthly compounding, before inflation and tax, for scale only and not as a return guarantee. Fee figures: mpf.hk fee-history database (22 October 2026). Rules: MPFA full-portability introduction, employee FAQs and transfer pages, and the Government gazette notice of 16 October 2026. Awareness data: GUM MPF Confidence Index survey (13–15 August 2026, 808 respondents). This article is information and analysis, not personal investment advice.